Hall v. DeCuir
1877 U.S. LEXIS 2197, 95 U.S. 485, 24 L. Ed. 547 (1878)
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Rule of Law:
A state law that requires a common carrier engaged in interstate commerce to provide equal accommodations to all passengers, regardless of race, is an unconstitutional regulation of interstate commerce because it imposes a direct burden on that commerce and interferes with the need for national uniformity.
Facts:
- Benson was the owner and master of the steamboat 'Governor Allen,' which was enrolled and licensed for the coasting trade under federal law.
- The steamboat was engaged in carrying passengers and freight on the Mississippi River between New Orleans, Louisiana, and Vicksburg, Mississippi.
- Benson's steamboat maintained a customary rule of providing two separate cabins for the accommodation of passengers: one exclusively for white persons and another exclusively for persons of color.
- DeCuir, a woman of color, boarded the steamboat in New Orleans to travel to a landing called the Hermitage, which was also within Louisiana.
- DeCuir requested passage in the cabin assigned to white passengers but was refused by the steamboat's clerk due to her race.
- The clerk offered DeCuir accommodation in the cabin assigned to persons of color, which she declined.
- At the time, a Louisiana statute enacted in 1869 required public conveyances to provide equal rights and privileges to all persons without discrimination on account of race or color.
Procedural Posture:
- DeCuir sued Benson, the steamboat master, in the Eighth District Court for the Parish of New Orleans, seeking damages for being denied access to the whites-only cabin in violation of a Louisiana statute.
- The state district court rendered judgment in favor of DeCuir for $1,000.
- Benson appealed to the Supreme Court of Louisiana, where he was the appellant and DeCuir was the appellee.
- The Supreme Court of Louisiana affirmed the judgment of the trial court.
- After Benson's death, his administratrix, Eliza Hall, sought and obtained a writ of error from the Supreme Court of the United States to review the judgment of the Louisiana Supreme Court. Hall is the plaintiff-in-error and DeCuir is the defendant-in-error.
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Issue:
Does a Louisiana law requiring common carriers to give all persons equal rights and privileges in all parts of the conveyance, without regard to race or color, violate the Commerce Clause of the U.S. Constitution when applied to a steamboat operator engaged in interstate commerce?
Opinions:
Majority - Chief Justice Waite
Yes. The Louisiana statute is an unconstitutional regulation of interstate commerce. State legislation that seeks to impose a direct burden upon interstate commerce or interfere directly with its freedom encroaches upon the exclusive power of Congress. Although the statute purports to control the carrier only while within Louisiana, it necessarily affects the carrier's conduct throughout the entire interstate voyage. Uniformity in regulations is a necessity for interstate carriers, and allowing each state to impose its own rules—one requiring integration, another perhaps requiring segregation—would lead to great inconvenience and hardship. The power to establish such uniform regulations for interstate commerce rests exclusively with Congress, and its inaction on the subject is equivalent to a declaration that interstate commerce shall remain free and untrammeled, leaving carriers to adopt their own reasonable rules.
Concurring - Justice Clifford
Yes. The judgment should be reversed because the Louisiana statute is an unconstitutional regulation of commerce. The power to regulate commerce, which includes navigation, is vested exclusively in Congress for subjects that are national in character and require a uniform system of regulation. The steamboat was federally enrolled and licensed for the coasting trade, which grants it privileges under federal law that a state cannot abridge by imposing additional, conflicting conditions. If Louisiana can forbid segregation, another state on the same route could require it, making it impossible for the carrier to operate. This subject requires a single, uniform rule, and therefore the power to regulate it belongs exclusively to Congress, rendering the state law void as applied to this interstate carrier.
Analysis:
This decision significantly reinforced the 'Dormant' Commerce Clause doctrine, establishing that states cannot enact laws that directly regulate interstate carriers, even for conduct occurring entirely within the state's borders. By prioritizing the need for national uniformity in commerce, the Court effectively struck down a state-level civil rights law intended to prevent segregation in public accommodations. The ruling created a precedent that limited states' ability to legislate on matters of racial discrimination in interstate transportation, leaving such regulations exclusively to Congress, which had not acted. This case is often contrasted with later cases where the Court allowed states to mandate segregation under their police powers, demonstrating the complex interplay between the Commerce Clause, federal power, and civil rights in the late 19th century.
